On July 21st, OSHA announced a new rule effective January 1, 2024 (contingent on OMB approval) requiring many industries to begin electronically submitting most OSHA 300 Log / 301 Injury data annually beginning March 2, 2024 for calendar year 2023. It also clarifies electronic 300A reporting requirements. Generally speaking, the following establishments must submit injury-related information to OSHA annually by March 2nd:
- Appendix A – listed establishments having 20–249 employees at any time during the previous calendar year must submit required Form 300A information to OSHA;
- Establishments having 250 or more employees at any time during the previous calendar year that are required to keep injury records must submit required Form 300A information to OSHA; and
- Appendix B – listed establishments having 100 or more employees at any time during the previous calendar year must submit Form 300 and 301 required information to OSHA in addition submitting the required Form 300A information.
Appendix A applies broadly to manufacturing, warehousing, and retail establishments. Appendix B applies to a slightly reduced and more specific set of establishments. The complete published rule and comments can be found here: [PDF].The last four pages are the amended rule itself.
If your establishment is subject to this rule, you should begin considering how you will manage the submittals to protect employee privacy, among other things. If you have any questions about the particular information OSHA requires you to submit (or exempts) from submittal, Goldenberg Schneider, LPA can help.